The governing board's responsibility for administration
of the investment program is delegated to the Treasurer, who shall
establish written procedures for the operation of the investment program
consistent with these investment guidelines. Such procedures shall
include an adequate internal control structure to provide a satisfactory
level of accountability based on a data base or records incorporating
description and amounts of investments, transaction dates and other
relevant information and regulate the activities of subordinate employees.

All participants in the investment process shall seek to act responsibly
as custodians of the public trust and shall avoid any transaction
that might impair public confidence in the Village of Woodridge to
govern effectively.

Investments shall be made with judgment and care, under circumstances
then prevailing, which persons of prudence, discretion and intelligence
exercise in the management of their own affairs, not for speculation,
but for investment, considering the safety of the principal as well
as the probable income to be derived.

All participants involved in the investment process shall refrain
from personal business activity that could conflict with proper execution
of the investment program or which could impair their ability to make
impartial investment decisions.

It is the policy of the Village of Woodridge for all moneys collected
by any officer or employee of the government to transfer those funds
to the Treasurer within three days of deposit or within the time period
specified in law, whichever is shorter.

The Treasurer is responsible for establishing and maintaining an
internal control structure to provide reasonable, but not absolute,
assurance that deposits and investments are safeguarded against loss
from unauthorized use or disposition and that transactions are executed
in accordance with management's authorization and recorded properly
and are managed in compliance with applicable laws and regulations.

In accordance with the provisions of General Municipal Law § 10,
all deposits of the Village of Woodridge, including certificates of
deposit and special time deposits, in excess of the amount insured
under the provisions of the Federal Deposit Insurance Act shall be
secured:

By a pledge of eligible securities with an aggregate market value
as provided by General Municipal Law § 10 equal to the aggregate
amount of deposits from the categories designated in Appendix A to
the policy.[1]

By an eligible irrevocable letter of credit issued by a qualified
bank other than the bank with the deposits in favor of the government
for a term not to exceed 90 days with an aggregate value equal to
140% of the aggregate amount of deposits and the agreed-upon interest,
if any. A qualified bank is one whose commercial paper and other unsecured
short-term debt obligations are rated in one of the three highest
rating categories by at least one nationally recognized statistical
rating organization or by a bank that is in compliance with applicable
federal minimum risk-based capital requirements.

By an eligible surety bond payable to the government for an amount
at least equal to 100% of the aggregate amount of deposits and the
agreed-upon interest, if any, executed by an insurance company authorized
to do business in New York State, whose claims-paying ability is rated
in the highest rating category by at least two nationally recognized
statistical rating organizations.

The security agreement shall provide that eligible securities are
being pledged to secure local government deposits together with agreed-upon
interest, if any, and any costs or expenses arising out of the collection
of such deposits upon default. It shall also provide the conditions
under which the securities may be sold, presented for payment, substituted
or released and the events which will enable the local government
to exercise its rights against the pledged securities. In the event
that the securities are not registered or inscribed in the name of
the local government, such securities shall be delivered in a form
suitable for transfer or with an assignment in blank to the Village
of Woodridge or its custodial bank.

The custodial agreement shall provide that securities held by the
bank or trust company or agent of and custodian for the local government
will be kept separate and apart from the general assets of the custodial
bank or trust company and will not, in any circumstances, be commingled
with or become part of the backing for any other deposit or other
liabilities. The agreement should also describe that the custodian
shall confirm the receipt, substitution or release of the securities.
The agreement shall provide for the frequency of revaluation of eligible
securities and for the substitution of securities when a change in
the rating of a security may cause ineligibility. Such agreement shall
include all provisions necessary to provide the local government a
perfected interest in the securities.

As authorized by General Municipal Law § 11, the Village
of Woodridge authorizes the Treasurer to invest moneys not required
for immediate expenditure for terms not to exceed its projected cash
flow needs in the following types of investments:

Obligations issued pursuant to Local Finance Law § 24.00
or 25.00 (with approval of the State Comptroller) by any municipality,
school district or district corporation other than the Village of
Woodridge.

Obligations of public authorities, public housing authorities, urban
renewal agencies and industrial development agencies where the general
state statutes governing such entities or whose specific enabling
legislation authorizes such investments.

All investment obligations shall be payable or redeemable at the
option of the Village of Woodridge within such times as the proceeds
will be needed to meet expenditures for purposes for which the moneys
were provided and, in the case of obligations purchased with the proceeds
of bonds or notes, shall be payable or redeemable at the option of
the Village of Woodridge within two years of the date of purchase.

The Village of Woodridge shall maintain a list of financial
institutions and dealers approved for investment purposes and establish
appropriate limits to the amount of investments which can be made
with each financial institution or dealer. All financial institutions
with which the local government conducts business must be credit worthy.
Banks shall provide their most recent Consolidated Report of Condition
(Call Report) at the request of the Village of Woodridge. Security
dealers not affiliated with a bank shall be required to be classified
as reporting dealers affiliated with the New York Federal Reserve
Bank, as primary dealers. The Treasurer is responsible for evaluating
the financial position and maintaining a listing of proposed depositaries,
trading partners and custodians. Such listing shall be evaluated at
least annually.

By participation in a cooperative investment program with another
authorized governmental entity pursuant to Article 5G of the General
Municipal Law where such program meets all the requirements set forth
in the Office of the State Comptroller Opinion No. 88-46, and the
specific program has been authorized by the governing board.

All purchased obligations, unless registered or inscribed in the
name of the local government, shall be purchased through, delivered
to and held in the custody of a bank or trust company. Such obligations
shall be purchased, sold or presented for redemption or payment by
such bank or trust company only in accordance with prior written authorization
from the officer authorized to make the investment. All such transactions
shall be confirmed in writing to the Village of Woodridge by the bank
or trust company. Any obligation held in the custody of a bank or
trust company shall be held pursuant to a written custodial agreement
as described in General Municipal Law § 10.

The custodial agreement shall provide that securities held by the
bank or trust company as agent of and custodian for the local government
will be kept separate and apart from the general assets of the custodial
bank or trust company and will not, in any circumstances, be commingled
with or become part of the backing for any other deposit or other
liabilities. The agreement shall describe how the custodian shall
confirm the receipt and release of the securities. Such agreement
shall include all provisions necessary to provide the local government
a perfected interest in the securities.